ADA AS is "dirt" as well, is that included? It's clay loam, we have million's of metric cubic meter's worth in rice paddies. Pretty much the same stuff.

Non commercial will not suit the definition either.....since many use Miracle Grow etc.......and it's processed etc.......

Revise the definition somewhat to account for this? Or leave it be?

Fraternity of Processed Earth Substance?

I do get the point though, it is not true dirt per se but if I were to dig up my back yard, once I get through the first 10' of fertilized sand I would hit clay. Our subdevelopment used to be a nice orange grove before they razed it, dumped layer upon layer of fill crap then built houses all over the place. Sad, but true.